WEBVTT

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>>SPEAKER: Good afternoon ladies and
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gentlemen, my name is Lynn Banks from
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the US customs and border protection
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office of trade and relations. Thank
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you for joining us today for the Never
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Screw Fasteners of 7318 Again! Webinar.
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Today's webinar is part of the 2023
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educations commodity specific webinar
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series and it has an expected duration
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of 90 minutes.
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We have a few housekeeping items,
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everybody will be kept on mute during the
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presentations so that we can keep the
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line clear of any background noise. If
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you have any questions or comments, we
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invite you to type them into the
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chatterbox at any time during the
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presentation. We will answer as many
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questions as we can from the chat box
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at the end of the presentation and the
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continuing education credit code will be
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placed in the WebEx chat box during the
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presentation. Today's presenter is
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national import specialist Jennifer
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Jamison, Mr. Jamieson, over to you!
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>>SPEAKER: Thank you, hello everyone
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and that afternoon and good morning,
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thank you for being here. I would like
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to welcome you on behalf of the CPP
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office of trade and the national
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commodity specialist division. I am
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Jennifer Jamison and I am the national
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import specialist for a line that
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includes base metal goods such as
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fasteners, mountings and fittings,
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locks, safes and ornamental articles.
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Today, I am going to be talking about the
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classification of fasteners of heading
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7318. This presentation should last
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about 60 minutes and you can post
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questions in the chat box and I will try
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my best to answer them as I see them,
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but to be honest this is new for me and
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I will adjust accordingly. I will also
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have time at the end for questions on
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anything on the presentation.
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So, here are the mission statements for
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both CPP and the office of trade. The
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intent of this webinar is to facilitate
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the correct entry of merchandise into
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the United States and thereby help
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achieve one of our office of the trade
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missions.
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This disclaimer let's see now that this
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webinar is advisory only and not
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binding. As you all know, I am sure,
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classification can be really complex and
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there is a lot of factors to consider so
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reliant solely on the general
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information that is included today may
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not be considered reasonable care.
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I have included a lot of photos in this
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presentation to show as examples of the
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fasteners and the details that we are
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discussing. All of the photos are in the
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public domain and if any brands are
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identifiable, their inclusion in this
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presentation does not represent an
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endorsement or approval by CBP, they are
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purely included to show you the best
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examples of the topic that is being
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covered. I
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am hoping that this presentation will
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provide you with a lot
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with a lot of helpful information, but as
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I just mentioned, there is a lot of
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complicated factors that can be involved
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in the classification of merchandise.
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So, I want to remind you about the
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binding ruling program that allows you
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to get a binding classification
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determination for a specific product.
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You can apply for the ruling using the
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website that is listed on your screen.
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It is free and you should get a
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response within 30 days and you will get
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a classification that you can use at any
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port in the United States.
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If you do request a binding ruling
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classification, please include as much
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information as possible so we can
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determine the classification. And that
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would include information like the
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country of origin, maybe send a sample
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or a picture or technical drawings or
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links to website about the item. We
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need to know what the article is made
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of, if it is a composite good, we need
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may be a value and weight breakdown and
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how it functions, where it is used, that
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kind of thing.
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So, I have got a lot of information to
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cover today, so I am going to go quickly
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through some of the more straightforward
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sections so that I can focus more time
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on some of the more tricky ones. But,
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please know that you will have access to
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these slides when this presentation is
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posted and it is going to be posted at
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the link in this slide here. And it is
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my understanding that it will be
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available in about two or three weeks.
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So, let's get started. Having 7318
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covers screws, bolts, nuts, coach
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screws, screw hooks, rivets, corridors,
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cotter pins, washers and similar
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articles of iron or steel. So, if a
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fastener is made of something other than
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iron or steel, then it will be
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classified under the chapter for that
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material. So, for example screws made of
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copper would be classified in chapter 74
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and screws made of aluminum would be
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classified in chapter 76.
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The explanatory notes identify that all
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of these items are used to assemble or
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fasten goods that they can be readily
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disassembled without damage. So, to be
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classified in 7318, the item needs to
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have a fastening function. This heading
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is divided into two main sections.
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We have got the threaded articles and
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then the non-threaded articles. So,
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before we get into the specifics of
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7318, I want to start with some
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definitions and information that covers
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the whole heading. And if the first
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thing that I want everyone to know is
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that everything is class - everything
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that is classified under 7318 is
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considered to be parts of general use.
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So, I want to give you a very quick recap
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of what that means.
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The topic parts of general use is its own
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60 minute training webinar. I did one
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of those in 2019 and you can review it
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online if you want more details, but
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here are some key parts that I want you
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to keep in mind for today's webinar.
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Parts of general use are defined in
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section 15 note 2 and note 2A is where
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it specifies 7318 and similar articles
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of other base metals are considered part
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of general use. So, as I mentioned
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before, fasteners that are made of
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material other than iron or steel are
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classified by their constituent
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material. So, a screw that is made of
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copper would be classified in chapter
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74, but because that copper screw is
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similar to a screw of 7318, it would
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still be considered a part of general
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use.
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Explanatory note C to section 15 explains
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that part of general use when entered
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separately are not classified as a part
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of an article. Instead, they would be
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classified in the appropriate heading in
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section 15 which includes heading 7318.
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The notes from section 16 and 17 and
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chapters 90 - 96 tell us that if we are
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classifying an article that is considered
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a part of general use, if it is entered
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separately, it is excluded from
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classification in those sections and
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chapters. So, based on this information,
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if an item can be classified as a part
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of general use, it is excluded from
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classification under section 16 and 17
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which covers chapters 84 through 89 and
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also excluded for chapters 90 through
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96.
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And lastly I want to also note a common
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misunderstanding of the CBP term "general
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use ". A lot of people think because an
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item is made or designed for a very
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specific application then it is a part of
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that application, because it is not for
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general use. It is for specific use.
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For example, if a screw is made for a
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very specific part of a motor vehicle,
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then one might argue it is a part of that
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motor vehicle because it is specifically
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made for it. But, the term general use
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as defined by CBP here refer to the
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class of articles. The class is a
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general, but the articles can be
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specific. And items that are described
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under heading 7318 are considered a
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general use class of item. So, even if
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the screw is very specifically made for
00:12:51.208 --> 00:12:52.575
and only for use in a specific
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application, if it can be classified
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under 7318, and it is presented
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separately, it would meet the terms of
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heading 7318 and be classified in 7318
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and not be a part of the application.
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And I have an example of that that I
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will go over later in this
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presentation.
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And again, if you want more information
00:13:21.503 --> 00:13:22.527
specifically on parts of general use, you
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can check it out at this link, it is
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where all of the webinars live. This
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one was in 2019, so I believe they are
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sorted by year and it is located under
00:13:34.818 --> 00:13:36.403
the industrial and manufacturing
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materials section.
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Heading 7318 includes both screws and
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bolts. There is an informed compliance
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obligation or ICP for short called
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distinguishing bolts from screws making
00:13:58.290 --> 00:14:00.314
the distinction between a bolt and a
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screw. Now, I will not have time to go
00:14:02.303 --> 00:14:04.673
through all of these details in this
00:14:04.673 --> 00:14:05.673
presentation, but I do want to touch on a
00:14:05.673 --> 00:14:07.678
few areas. But, for more information,
00:14:07.678 --> 00:14:12.387
check out that ICP.
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CBP uses the American National standards
00:14:18.407 --> 00:14:20.414
Inst. Or ANSI for short and the
00:14:20.414 --> 00:14:36.377
American Society of American engineers
00:14:36.377 --> 00:14:40.630
or ASME for short to distinguish bolts
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from screws and the standard in
00:14:42.624 --> 00:14:44.775
particular that I'm looking at here is
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identified as B 18.2.1. And that
00:14:49.781 --> 00:14:51.801
standard states that both Olson and
00:14:51.801 --> 00:14:58.820
screws are externally threaded fasteners.
00:14:58.820 --> 00:15:00.842
A bolt is designed to be threaded
00:15:00.842 --> 00:15:02.839
through holes in assemble parts and
00:15:02.839 --> 00:15:03.837
normally intended to be heightened or
00:15:03.837 --> 00:15:09.071
released by torquing a nut. A screw is
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designed to be inserted into holes in
00:15:47.265 --> 00:15:48.260
separate parts, but it can marry up with
00:15:48.260 --> 00:15:50.243
a preformed internal thread or form its
00:15:50.243 --> 00:15:52.258
own thread. And a screw is tightened or
00:15:52.258 --> 00:15:57.456
released by torquing the head. Now,
00:15:57.456 --> 00:15:59.459
because of the basic design, it is
00:15:59.459 --> 00:16:00.482
possible to use certain screws in
00:16:00.482 --> 00:16:07.239
combination with a nut. So the presence
00:16:07.239 --> 00:16:09.240
of a nut does not help us in the
00:16:09.240 --> 00:16:11.264
classification, but any externally
00:16:11.264 --> 00:16:12.581
threaded fastener which has the majority
00:16:12.581 --> 00:16:14.616
of design characteristics that help a
00:16:14.616 --> 00:16:17.820
fastener to be used in a tapped or
00:16:17.820 --> 00:16:22.404
preformed hole is a screw regardless how
00:16:22.404 --> 00:16:24.813
it is used in its surface application.
00:16:24.813 --> 00:16:26.986
And those additional design
00:16:26.986 --> 00:16:30.816
characteristics are discussed and that
00:16:30.816 --> 00:16:31.810
distinction bolts from screws ICP, so
00:16:31.810 --> 00:16:41.856
please refer to that when making a
00:16:41.856 --> 00:16:41.858
determination.
00:16:41.858 --> 00:16:43.831
I want to point out that as of today, all
00:16:43.831 --> 00:16:45.866
of the fasteners of 7318 that originate
00:16:45.866 --> 00:16:53.054
in China are subject to an additional
00:16:53.054 --> 00:16:55.050
section 301 trade remedies. Nuts are
00:16:55.050 --> 00:16:57.068
subject to one case and all of the other
00:16:57.068 --> 00:16:58.049
fasteners are subject to another. Rather
00:16:58.049 --> 00:17:00.073
than keep mentioning that, I have added
00:17:00.073 --> 00:17:02.790
a small red flag on each slide to
00:17:02.790 --> 00:17:05.989
remind you that 301 trade remedies apply
00:17:05.989 --> 00:17:10.202
for goods from China. You can check the
00:17:10.202 --> 00:17:12.233
latest tariff to verify the trade
00:17:12.233 --> 00:17:13.792
remedy details, but as of today, nuts
00:17:13.792 --> 00:17:18.574
from China are subject to an additional
00:17:18.574 --> 00:17:20.576
7.5% trade remedies and all other
00:17:20.576 --> 00:17:27.396
fasteners from China are subject to an
00:17:27.396 --> 00:17:28.389
additional 25%.
00:17:28.389 --> 00:17:40.814
Also, there are a few anti-dumping and
00:17:40.814 --> 00:17:41.809
countervailing duty cases to keep in
00:17:41.809 --> 00:17:49.824
mind. They are for threaded rod and
00:17:49.824 --> 00:17:51.847
helical spring lock washers. I will
00:17:51.847 --> 00:17:57.315
mention these again when we come to
00:17:57.315 --> 00:17:58.314
those products. I will not have time to
00:17:58.314 --> 00:18:00.313
get into the cases specifically, but I
00:18:00.313 --> 00:18:02.278
want to remind you that these cases are
00:18:02.278 --> 00:18:05.390
in place for these products from these
00:18:05.390 --> 00:18:06.395
countries.
00:18:06.395 --> 00:18:13.232
Okay, so let's get into 7318. To be
00:18:13.232 --> 00:18:15.269
threaded, as I mentioned earlier it
00:18:15.269 --> 00:18:17.777
starts with a threaded article and to be
00:18:17.777 --> 00:18:23.656
threaded, the fastener must have a
00:18:23.656 --> 00:18:24.685
complete thread. And a complete thread
00:18:24.685 --> 00:18:26.692
is designed as a ridge of uniform
00:18:26.692 --> 00:18:29.152
section in the form of a helix where the
00:18:29.152 --> 00:18:35.094
external or internal surface of the
00:18:35.094 --> 00:18:37.119
cylinder. So, what you need to know is
00:18:37.119 --> 00:18:39.094
that it needs a complete thread in a
00:18:39.094 --> 00:18:45.834
spiral form, think like a slinky in that
00:18:45.834 --> 00:18:45.836
form.
00:18:45.836 --> 00:18:47.861
This fasteners looks like it might be
00:18:47.861 --> 00:18:51.647
threaded, but it actually has annular
00:18:51.647 --> 00:18:53.632
grooves, it does not have threads not
00:18:53.632 --> 00:18:54.641
form a helix, because of that, this
00:18:54.641 --> 00:19:00.376
fastener would be considered
00:19:00.376 --> 00:19:01.373
non-threaded.
00:19:01.373 --> 00:19:05.423
And of these examples look non-threaded,
00:19:05.423 --> 00:19:08.575
but they are actually incomplete or
00:19:08.575 --> 00:19:10.758
unfinished hex head steel Screws and
00:19:10.758 --> 00:19:21.615
they would be considered threaded based
00:19:21.615 --> 00:19:23.601
on GRI 2A based on the classification of
00:19:23.601 --> 00:19:25.607
goods that are incomplete or
00:19:25.607 --> 00:19:31.808
unfinished. .
00:19:31.808 --> 00:19:35.990
So, let's get the subheadings. The first
00:19:35.990 --> 00:19:39.176
one provides for coach screws. Coach
00:19:39.176 --> 00:19:42.788
screws are large heavy-duty wood screws
00:19:42.788 --> 00:19:44.796
that have a square or a hex dog and all
00:19:44.796 --> 00:19:52.096
head and they are on slotted. The coach
00:19:52.096 --> 00:19:54.081
screws have a steep cutting threads and
00:19:54.081 --> 00:19:56.074
they cannot accommodate him not. Coach
00:19:56.074 --> 00:20:23.994
screws are also known as screw spikes,
00:20:23.994 --> 00:20:27.998
lag screws and lag bolts. And they are
00:20:27.998 --> 00:20:31.376
used to fix railroad lines or to a
00:20:31.376 --> 00:20:34.022
sample rafters or similar heavy
00:20:34.022 --> 00:20:50.591
woodwork.
00:20:50.591 --> 00:20:55.802
7318.12 provides for other wood screws.
00:20:55.802 --> 00:20:57.793
Wood screws can resemble self tapping
00:20:57.793 --> 00:21:11.049
screws and they can be tricky. In 2018 ,
00:21:11.049 --> 00:21:14.999
the core of international trade decided
00:21:14.999 --> 00:21:16.771
a case that considered if a few specific
00:21:16.771 --> 00:21:17.979
fasteners were wood screws or self
00:21:17.979 --> 00:21:22.766
tapping screws. That case was GRK
00:21:22.766 --> 00:21:26.799
Canada vs. United States. And that case
00:21:26.799 --> 00:21:33.453
has given us this definition of a wood
00:21:33.453 --> 00:21:35.448
screw. It is "unscrew that forms its
00:21:35.448 --> 00:21:36.644
own threads by compressing surrounding
00:21:36.644 --> 00:21:40.371
material designed to fasten would to wood
00:21:40.371 --> 00:21:44.387
or the other fibrous material. "
00:21:44.387 --> 00:21:49.369
There are two key parts of this
00:21:49.369 --> 00:22:04.389
definition. First, it is a screw that
00:22:04.389 --> 00:22:09.012
forms its own threads by compressing
00:22:09.012 --> 00:22:10.393
surrounding material and two it is used
00:22:10.393 --> 00:22:16.617
to fasten would to wood or other fibrous
00:22:16.617 --> 00:22:18.623
materials. Starting with the second one
00:22:18.623 --> 00:22:22.985
first as you might expect, they are used
00:22:22.985 --> 00:22:25.403
for plywood, lumber or other types of
00:22:25.403 --> 00:22:33.244
fibrous material. But, just because a
00:22:33.244 --> 00:22:34.283
screw is used to fasten wood material is
00:22:34.283 --> 00:22:36.286
not enough to call it a wood screw. You
00:22:36.286 --> 00:22:38.413
need to look at the attributes of the
00:22:38.413 --> 00:22:40.424
actual screw. So, let's take a look at
00:22:40.424 --> 00:22:42.411
some of those attributes. We will start
00:22:42.411 --> 00:22:44.400
with the first points that are listed in
00:22:44.400 --> 00:22:48.015
this definition that a wood screw forms
00:22:48.015 --> 00:22:54.984
its own threads by compressing
00:22:54.984 --> 00:22:55.987
surrounding material.
00:22:55.987 --> 00:22:57.600
In order to form its own threads, wood
00:22:57.600 --> 00:23:01.239
screws bite their way into the wood.
00:23:01.239 --> 00:23:03.237
And to be able to do that, wood screws
00:23:03.237 --> 00:23:05.572
are generally tapered and they will
00:23:05.572 --> 00:23:08.578
always have a gimlet point which is a
00:23:08.578 --> 00:23:13.257
sharp tone point with threads, you can
00:23:13.257 --> 00:23:14.268
see how sharp that is and that threads
00:23:14.268 --> 00:23:17.611
go all the way down the point. Wood
00:23:17.611 --> 00:23:20.389
screws also have steep cutting threads
00:23:20.389 --> 00:23:24.224
which are wider, deeper ridges. When
00:23:24.224 --> 00:23:26.202
the screw is inserted into wood, the
00:23:26.202 --> 00:23:28.792
material that it is displacing as it
00:23:28.792 --> 00:23:38.749
bites its way through generally stays
00:23:38.749 --> 00:23:39.775
inside the wood and those course threads
00:23:39.775 --> 00:23:41.767
inside the screw in addition to helping
00:23:41.767 --> 00:23:43.758
bite through the material it also
00:23:43.758 --> 00:23:44.765
provides space to hold the material that
00:23:44.765 --> 00:23:46.754
is being pushed out of the way as the
00:23:46.754 --> 00:23:48.763
screw enters the wood. Wood screws
00:23:48.763 --> 00:23:51.417
generally have fewer threads per inch
00:23:51.417 --> 00:23:53.426
than a tapping screw. They are usually
00:23:53.426 --> 00:23:56.487
threaded along two thirds of the shank,
00:23:56.487 --> 00:24:02.237
they almost always have slotted or
00:24:02.237 --> 00:24:03.263
processed heads and because of the point
00:24:03.263 --> 00:24:05.384
in tapering that they have, they cannot
00:24:05.384 --> 00:24:06.382
take a nut.
00:24:06.382 --> 00:24:11.469
Now, I will compare wood screws and self
00:24:11.469 --> 00:24:13.457
tapping screws in a moment, but I will
00:24:13.457 --> 00:24:14.469
continue down the tariff and cover hooks
00:24:14.469 --> 00:24:17.012
and rings and before I move onto that I
00:24:17.012 --> 00:24:21.426
see there is a message about showing
00:24:21.426 --> 00:24:22.424
another slide and I think rather than
00:24:22.424 --> 00:24:25.004
just to go back I will show you those
00:24:25.004 --> 00:24:31.801
again at the end of the presentation.
00:24:31.801 --> 00:24:37.036
So, screw hooks and rings are provided
00:24:37.036 --> 00:24:39.014
for in 73 18.13. They are used to
00:24:39.014 --> 00:24:41.822
suspend or fasten other objects and as
00:24:41.822 --> 00:24:42.831
you can see here, one end is bent into
00:24:42.831 --> 00:24:47.383
an angle or a hook or a ring and the
00:24:47.383 --> 00:24:52.569
other side has a gimlet point and steep
00:24:52.569 --> 00:24:54.382
cutting threads. These screw hooks and
00:24:54.382 --> 00:25:05.029
rings will not accommodate A nut. And
00:25:05.029 --> 00:25:06.365
let's dive into self tapping screws that
00:25:06.365 --> 00:25:08.802
are covered in 73 18.14.
00:25:08.802 --> 00:25:17.171
So,
00:25:17.171 --> 00:25:19.179
a tap is something that can be inserted
00:25:19.179 --> 00:25:20.167
into a whole and create a threading for
00:25:20.167 --> 00:25:22.162
the screw to fasten into. But, self
00:25:22.162 --> 00:25:24.160
tapping screws and cut their own way
00:25:24.160 --> 00:25:25.170
into the material and they do not need
00:25:25.170 --> 00:25:27.172
that. They can pierce thin metals and
00:25:27.172 --> 00:25:29.821
dig into the material to cut their own
00:25:29.821 --> 00:25:37.083
threads. Unlike wood screws that
00:25:37.083 --> 00:25:39.074
compress the surrounding aerial, tapping
00:25:39.074 --> 00:25:44.344
screws cut the material that they are
00:25:44.344 --> 00:25:45.364
being fastened into. So, let's take a
00:25:45.364 --> 00:25:47.336
look at the CIT definition of a self
00:25:47.336 --> 00:25:48.774
tapping screw from that same court case,
00:25:48.774 --> 00:25:56.040
GRK Canada vs. the United States.
00:25:56.040 --> 00:26:01.076
It says "a self tapping screws is a
00:26:01.076 --> 00:26:02.064
specially hardened screw that meets
00:26:02.064 --> 00:26:04.064
minimum torsional strength
00:26:04.064 --> 00:26:07.639
requirements, that can cut away material
00:26:07.639 --> 00:26:09.637
to form a mating thread in non-fibrous
00:26:09.637 --> 00:26:11.642
materials and is designed to fasten
00:26:11.642 --> 00:26:16.415
non-fibrous materials, such as metal to
00:26:16.415 --> 00:26:17.413
either fibrous or non-fibrous materials."
00:26:17.413 --> 00:26:22.248
So, that is a lot to unpack in that
00:26:22.248 --> 00:26:27.411
definition, so let's start breaking them
00:26:27.411 --> 00:26:28.424
down separately.
00:26:28.424 --> 00:26:29.415
First, it says that self tapping screws
00:26:29.415 --> 00:26:39.711
are specially hardened and meet minimum
00:26:39.711 --> 00:26:41.718
torsional strength requirements. These,
00:26:41.718 --> 00:26:43.704
of course are not attributes that you
00:26:43.704 --> 00:26:44.703
would be able to see on the actual
00:26:44.703 --> 00:26:46.700
fastener, but that information would
00:26:46.700 --> 00:26:47.691
likely be noted on the technical drawing.
00:26:47.691 --> 00:26:49.698
Self tapping screws need to be strong
00:26:49.698 --> 00:26:51.715
to cut their way into really hard
00:26:51.715 --> 00:26:52.711
materials, so they may be designed to be
00:26:52.711 --> 00:26:58.218
coated with materials that provide extra
00:26:58.218 --> 00:27:00.211
hardening and strength. They are also
00:27:00.211 --> 00:27:00.616
designed to meet minimum torsional
00:27:00.616 --> 00:27:02.641
strength requirements which means the
00:27:02.641 --> 00:27:07.604
ability of the screw to with they had a
00:27:07.604 --> 00:27:15.268
twisting load as they are twisted and
00:27:15.268 --> 00:27:16.253
forced into the material.
00:27:16.253 --> 00:27:18.254
Then, the definition says that self
00:27:18.254 --> 00:27:20.437
tapping screws can cut away material to
00:27:20.437 --> 00:27:26.534
form a mating thread. When it cuts away
00:27:26.534 --> 00:27:28.505
material, that material will be removed
00:27:28.505 --> 00:27:30.504
when the screw is inserted and you will
00:27:30.504 --> 00:27:33.424
likely get chips of that material that
00:27:33.424 --> 00:27:34.472
you are installing into. And lastly,
00:27:34.472 --> 00:27:35.795
self tapping screws are designed to
00:27:35.795 --> 00:27:39.815
fasten non-fibrous materials such as
00:27:39.815 --> 00:27:44.635
metal to either fibrous materials such
00:27:44.635 --> 00:27:45.605
as wood or two other non-fibrous
00:27:45.605 --> 00:27:52.357
materials. So, they can be used to
00:27:52.357 --> 00:27:54.348
fasten into harder materials like thin
00:27:54.348 --> 00:27:55.355
sheets of metal, marble, slate, plastics,
00:27:55.355 --> 00:28:00.374
etc., but they can also be used in wood
00:28:00.374 --> 00:28:00.376
applications.
00:28:00.376 --> 00:28:05.600
ICA chat, is there an easy way to
00:28:05.600 --> 00:28:06.598
calculate the thread shank diameter that
00:28:06.598 --> 00:28:12.991
is a part of the code? We talk about
00:28:12.991 --> 00:28:15.015
the diameter with machine screws, so I
00:28:15.015 --> 00:28:17.825
will hold off on that question. In the
00:28:17.825 --> 00:28:19.160
meantime, let's take a look at the
00:28:19.160 --> 00:28:23.815
visible characteristics of self tapping
00:28:23.815 --> 00:28:29.225
screws.
00:28:29.225 --> 00:28:31.408
Self tapping screws have a tapered or
00:28:31.408 --> 00:28:34.028
pointed end. They can have course
00:28:34.028 --> 00:28:38.622
threading or they can have fine threading
00:28:38.622 --> 00:28:40.624
with specialized points. They are
00:28:40.624 --> 00:28:42.612
usually threaded along the entire length
00:28:42.612 --> 00:28:44.620
and they generally have more rads per
00:28:44.620 --> 00:28:51.874
inch than a wood screw. They have
00:28:51.874 --> 00:28:52.904
slotted, recessed or wrenching heads and
00:28:52.904 --> 00:28:54.870
they are available in various thread and
00:28:54.870 --> 00:28:56.878
point styles and I will show you that on
00:28:56.878 --> 00:28:58.202
the next slide and they cannot take a
00:28:58.202 --> 00:29:03.218
nut. So, here are some examples of self
00:29:03.218 --> 00:29:06.245
tapping screws, this topic screw here is
00:29:06.245 --> 00:29:08.281
actually a drywall screw, it has a bugle
00:29:08.281 --> 00:29:12.187
head, it has a gimlet point and it has a
00:29:12.187 --> 00:29:15.173
steep cutting thread. Customs has
00:29:15.173 --> 00:29:20.204
routinely classified drywall screws as
00:29:20.204 --> 00:29:22.248
tapping screws. This example here, you
00:29:22.248 --> 00:29:25.027
can see has a triangular point and this
00:29:25.027 --> 00:29:34.225
one here has a drill point.
00:29:34.225 --> 00:29:36.231
And a table comparing self tapping screws
00:29:36.231 --> 00:29:45.247
vs. wood screws, I have a chart coming
00:29:45.247 --> 00:29:47.239
up. So, tapping screws have a
00:29:47.239 --> 00:29:50.013
specialized points such as these. The
00:29:50.013 --> 00:29:53.222
tapping screws that have a B designation
00:29:53.222 --> 00:29:55.203
like in this column, they all have a B
00:29:55.203 --> 00:29:57.214
in their designation, those are going to
00:29:57.214 --> 00:30:02.021
have steep pitched threading. And
00:30:02.021 --> 00:30:03.018
generally, the tapping screws without the
00:30:03.018 --> 00:30:06.392
B designation these ones on the
00:30:06.392 --> 00:30:09.827
right-hand side, they are going to have
00:30:09.827 --> 00:30:10.199
machine screw threading which is fine
00:30:10.199 --> 00:30:15.057
threading, but they will have a point
00:30:15.057 --> 00:30:17.051
design that makes them capable of
00:30:17.051 --> 00:30:19.064
cutting through material and forming
00:30:19.064 --> 00:30:20.076
threads like a drilled point or slotted
00:30:20.076 --> 00:30:28.691
point or triangular point or fluted.
00:30:28.691 --> 00:30:30.668
So, as you can see, wood screws and a
00:30:30.668 --> 00:30:33.834
self tapping screws can be pretty
00:30:33.834 --> 00:30:34.862
similar and I put this chart together
00:30:34.862 --> 00:30:36.873
just using information that we have
00:30:36.873 --> 00:30:38.836
already covered to compare and contrast
00:30:38.836 --> 00:30:42.265
wood screws and tapping screws. The key
00:30:42.265 --> 00:30:44.280
point that I want to stress is that when
00:30:44.280 --> 00:30:46.872
you are looking at a screw, whether it
00:30:46.872 --> 00:30:49.836
be a wood screw or a self tapping screw,
00:30:49.836 --> 00:30:51.837
do not just consider what it is fastened
00:30:51.837 --> 00:30:54.250
into. Also, look for these
00:30:54.250 --> 00:30:55.242
characteristics that indicate that it
00:30:55.242 --> 00:30:57.678
might be a self tapping screws such as,
00:30:57.678 --> 00:31:01.824
it is specially hardened, it meets
00:31:01.824 --> 00:31:04.418
minimum torsional strength requirements,
00:31:04.418 --> 00:31:07.443
it is designed to fashion non-fibrous
00:31:07.443 --> 00:31:13.088
materials like metal to either fibrous or
00:31:13.088 --> 00:31:15.073
non-fibrous materials. And again, those
00:31:15.073 --> 00:31:17.065
three things are not something that you
00:31:17.065 --> 00:31:19.662
can see on the screw itself, so it is
00:31:19.662 --> 00:31:20.660
information that is likely available on
00:31:20.660 --> 00:31:25.044
the technical diagram. So, I recommend
00:31:25.044 --> 00:31:27.066
viewing that and I would also recommend
00:31:27.066 --> 00:31:29.037
reviewing the standard to which the
00:31:29.037 --> 00:31:34.406
screw is designed.
00:31:34.406 --> 00:31:40.028
I will leave that on for a second. I
00:31:40.028 --> 00:31:43.422
guess before we move onto the next
00:31:43.422 --> 00:31:46.783
section, does anybody have any questions
00:31:46.783 --> 00:31:57.490
about the wood or tapping screws? Okay,
00:31:57.490 --> 00:31:58.484
I am not being any come in right now,
00:31:58.484 --> 00:32:03.220
again you will have time to ask
00:32:03.220 --> 00:32:04.198
questions at the end.
00:32:04.198 --> 00:32:12.186
I will hold off on page 22 until the end.
00:32:12.186 --> 00:32:17.035
I will move on now to other screws and
00:32:17.035 --> 00:32:28.843
bolts that are classified under 7318.15.
00:32:28.843 --> 00:32:32.444
73 18.15.20 covers bolts and bolts and
00:32:32.444 --> 00:32:34.441
their nuts or washers entered or
00:32:34.441 --> 00:32:35.467
exported in the same shipment. These are
00:32:35.467 --> 00:32:41.453
member that a fastener can be called a
00:32:41.453 --> 00:32:43.467
bolt, but if the fastener has a majority
00:32:43.467 --> 00:32:46.459
of the design characteristics of a screw,
00:32:46.459 --> 00:32:48.985
then it is a screw, regardless of how it
00:32:48.985 --> 00:32:51.086
is used in its service application.
00:32:51.086 --> 00:32:55.025
Again, please refer to that
00:32:55.025 --> 00:32:57.640
distinguishing bolts from screws ICP and
00:32:57.640 --> 00:32:58.634
the characteristics to look for, but this
00:32:58.634 --> 00:33:07.008
is where you would classify a true
00:33:07.008 --> 00:33:07.010
bolt.
00:33:07.010 --> 00:33:09.596
Generally, alts are designed to be
00:33:09.596 --> 00:33:11.410
tightened or released by torquing a nut.
00:33:11.410 --> 00:33:16.413
They are cylindrical in shape, they
00:33:16.413 --> 00:33:20.441
rarely have a point, they have close
00:33:20.441 --> 00:33:21.438
thread with a slight incline and usually
00:33:21.438 --> 00:33:27.617
a part of the shank is unthreaded. The
00:33:27.617 --> 00:33:28.808
tariff starts breaking out a few
00:33:28.808 --> 00:33:31.795
specific alts, the first one is for
00:33:31.795 --> 00:33:35.996
tractor bolts. They have a mushroom
00:33:35.996 --> 00:33:42.021
shaped head and either an oval or
00:33:42.021 --> 00:33:44.008
elliptical neck. Track bolts are used
00:33:44.008 --> 00:33:45.853
as rail fasteners and sometimes referred
00:33:45.853 --> 00:34:07.249
to as a rail bolt.
00:34:07.249 --> 00:34:08.269
73 18.15.2030 covers structural bolts and
00:34:08.269 --> 00:34:10.802
these are really heavy duty both that
00:34:10.802 --> 00:34:14.235
are used in applications like building
00:34:14.235 --> 00:34:19.623
structures and you can identify these,
00:34:19.623 --> 00:34:32.213
because they will have the ASTM standard
00:34:32.213 --> 00:34:35.238
to which they are built stamped right on
00:34:35.238 --> 00:34:40.423
the head. So, look for either letter
00:34:40.423 --> 00:34:43.836
A320 fives or A4 90 stamped on the head
00:34:43.836 --> 00:34:47.622
and you will know that it is a
00:34:47.622 --> 00:35:17.861
structural bolts.
00:35:17.861 --> 00:35:18.851
Under 73 18.15.2041 bent bolts, there are
00:35:18.851 --> 00:35:21.830
two breakouts, first art right angle
00:35:21.830 --> 00:35:23.201
bolts which are self explanatory. And
00:35:23.201 --> 00:35:30.430
remember this section is for bolts and
00:35:30.430 --> 00:35:32.423
nuts and washers supported in the same
00:35:32.423 --> 00:35:35.202
shipment, so for this first example, if
00:35:35.202 --> 00:35:39.238
the knot, washer and all right angle
00:35:39.238 --> 00:35:41.267
bolts are all imported in the same
00:35:41.267 --> 00:35:44.162
shipment, they are classified as a right
00:35:44.162 --> 00:35:54.401
angle bolts. Is it safe to distinguish
00:35:54.401 --> 00:35:57.394
a vote from a screw is if the heads are
00:35:57.394 --> 00:36:00.664
going up more than halfway and not to
00:36:00.664 --> 00:36:09.012
what the bolt is being used in? The
00:36:09.012 --> 00:36:11.022
length of the thread is not enough to
00:36:11.022 --> 00:36:15.276
distinguish it. Again, that will be
00:36:15.276 --> 00:36:16.277
something that I will ask you to look at
00:36:16.277 --> 00:36:18.394
that distinguishing nuts from volts ICP,
00:36:18.394 --> 00:36:23.894
because there are some specific
00:36:23.894 --> 00:36:24.862
attributes to look for, but the length of
00:36:24.862 --> 00:36:27.454
the thread would not help you out in
00:36:27.454 --> 00:36:28.464
that determination.
00:36:28.464 --> 00:36:30.453
And yes, as you will see in the next one,
00:36:30.453 --> 00:36:37.383
a U bolt is a bent bolts. Other bent
00:36:37.383 --> 00:36:49.620
bolts are classified under 7318. 15.
00:36:49.620 --> 00:36:56.830
2046. And this would include fasteners
00:36:56.830 --> 00:36:58.827
like eye bolts, U bolts and hook bolts
00:36:58.827 --> 00:37:00.601
and if the nuts are entered in the same
00:37:00.601 --> 00:37:09.067
shipments, they are classified with these
00:37:09.067 --> 00:37:10.068
other bent bolts. I just wanted to
00:37:10.068 --> 00:37:12.062
point out that these two items that we
00:37:12.062 --> 00:37:13.626
have discussed a look very similar, the
00:37:13.626 --> 00:37:16.061
first one is a eye bolt, it has a blunt
00:37:16.061 --> 00:37:20.205
fit and used with a nut, that is
00:37:20.205 --> 00:37:24.521
classified under 73 18.15.20 as a bent
00:37:24.521 --> 00:37:26.485
bolts, but the second one here looks
00:37:26.485 --> 00:37:34.119
very similar, but it has a gimlet screw
00:37:34.119 --> 00:37:36.114
point and you could not use a nut with
00:37:36.114 --> 00:37:41.072
this one. This one is classified as a
00:37:41.072 --> 00:37:44.620
screw ring under 7318.13. So, if you
00:37:44.620 --> 00:37:47.451
have these rings, look for the type of
00:37:47.451 --> 00:37:51.432
point on those.
00:37:51.432 --> 00:37:53.427
And I also want to point out the
00:37:53.427 --> 00:38:01.816
difference between a eye bolt of 7318
00:38:01.816 --> 00:38:03.842
and a shouldered eye bolt, 7318 has a
00:38:03.842 --> 00:38:08.282
fastening function where is this
00:38:08.282 --> 00:38:09.311
shouldered eye bolt has a forged full
00:38:09.311 --> 00:38:12.444
circle here, this has a lifting function
00:38:12.444 --> 00:38:14.230
and the lifting eye bolt would be
00:38:14.230 --> 00:38:18.263
classified by its constituent material,
00:38:18.263 --> 00:38:20.289
it would not be classified in 7318,
00:38:20.289 --> 00:38:26.037
because it does not have a fastening
00:38:26.037 --> 00:38:26.039
function.
00:38:26.039 --> 00:38:31.208
Now we are moving further down this same
00:38:31.208 --> 00:38:34.428
subheading of other screws and bolts
00:38:34.428 --> 00:38:38.618
whether or not they are with nuts or
00:38:38.618 --> 00:38:42.034
washers and 73 18.15.40 provides for
00:38:42.034 --> 00:38:44.213
machine screws that are 9.5 mm or more in
00:38:44.213 --> 00:38:50.839
length and 3.2 mm or more in diameter
00:38:50.839 --> 00:38:52.825
and not including cap screws. So, for
00:38:52.825 --> 00:38:57.237
machine screws we start with measurement
00:38:57.237 --> 00:38:59.273
parameters. The length of a screw or
00:38:59.273 --> 00:39:07.436
bolt is measured from the point to the
00:39:07.436 --> 00:39:08.466
area where it would flush on the surface
00:39:08.466 --> 00:39:10.230
after installation. So, from the point
00:39:10.230 --> 00:39:14.650
to where it is going to be sitting where
00:39:14.650 --> 00:39:17.408
it is fastened into the material, that
00:39:17.408 --> 00:39:21.644
is the length we are measuring. And
00:39:21.644 --> 00:39:23.865
there was a question about measuring the
00:39:23.865 --> 00:39:27.860
diameter and I have a little tool to
00:39:27.860 --> 00:39:28.869
measure the diameter, so I don't have
00:39:28.869 --> 00:39:31.988
another idea right off the top of my
00:39:31.988 --> 00:39:41.191
head of how to best measure that, sorry
00:39:41.191 --> 00:39:41.193
about that.
00:39:41.193 --> 00:39:49.088
So, let's see, the length and the
00:39:49.088 --> 00:39:51.098
diameter of the machine screw is pretty
00:39:51.098 --> 00:39:55.850
much all we get in the guidance terrace
00:39:55.850 --> 00:39:57.839
for what is a machine screw, so we will
00:39:57.839 --> 00:40:06.495
look at the industry standards for more
00:40:06.495 --> 00:40:06.497
details.
00:40:06.497 --> 00:40:08.523
The other types of screws that we have
00:40:08.523 --> 00:40:10.489
looked at so far have tapered ends and
00:40:10.489 --> 00:40:14.071
pointed tips, but Sheen screws have a
00:40:14.071 --> 00:40:15.063
uniform diameter along the entire length
00:40:15.063 --> 00:40:17.045
of the shaft and a blunt point taking
00:40:17.045 --> 00:40:22.239
them look very similar to bolts. These
00:40:22.239 --> 00:40:26.031
screws are torqued by the head, but
00:40:26.031 --> 00:40:28.031
typically threaded through pre-existing
00:40:28.031 --> 00:40:29.023
capital holes and used with a nut. Sheen
00:40:29.023 --> 00:40:32.473
screws are typically designed with a
00:40:32.473 --> 00:40:34.441
finer more accurate threads than other
00:40:34.441 --> 00:40:37.253
fastener types and they are used to
00:40:37.253 --> 00:40:44.157
fasten metal to metal or metal the
00:40:44.157 --> 00:40:45.152
plastic. These are the attributes of
00:40:45.152 --> 00:40:49.264
the machine screw, but let's go back to
00:40:49.264 --> 00:40:50.274
the subheading language. Okay, so the
00:40:50.274 --> 00:40:52.485
question is do you measure from the
00:40:52.485 --> 00:40:55.609
outside of the thread or the Valley? I
00:40:55.609 --> 00:40:58.537
measure from the outside of the thread.
00:40:58.537 --> 00:41:25.399
Can you show where you would measure
00:41:25.399 --> 00:41:29.041
the diameter? I would measure like on
00:41:29.041 --> 00:41:31.033
this example I would measure the
00:41:31.033 --> 00:41:39.861
diameter anywhere right in here on the
00:41:39.861 --> 00:41:41.857
shank of the screw. Thank you, I cannot
00:41:41.857 --> 00:41:42.981
think of the word, the micrometer is what
00:41:42.981 --> 00:41:49.236
I used to measure the diameter and I
00:41:49.236 --> 00:41:51.231
have always had one, so I don't have
00:41:51.231 --> 00:41:57.445
another means to measure them.
00:41:57.445 --> 00:42:00.837
Okay, I think that is all of the
00:42:00.837 --> 00:42:01.849
questions. So, we are going to go back
00:42:01.849 --> 00:42:05.892
now and look at the attributes - we are
00:42:05.892 --> 00:42:10.668
going to go back to the subheading
00:42:10.668 --> 00:42:11.678
language on machine screws. After we
00:42:11.678 --> 00:42:13.676
talk about the length and diameter
00:42:13.676 --> 00:42:18.616
parameters, the subheading reads " not
00:42:18.616 --> 00:42:19.615
including cap screws " so, let's take a
00:42:19.615 --> 00:42:23.415
look at what that is. For
00:42:23.415 --> 00:42:30.505
classification purposes, cap screws are
00:42:30.505 --> 00:42:31.530
fasteners with a tax head with a washer
00:42:31.530 --> 00:42:33.538
phase or its equivalent, so let's take a
00:42:33.538 --> 00:42:37.256
look at what that means.
00:42:37.256 --> 00:42:38.602
Customs has a long-standing practice for
00:42:38.602 --> 00:42:44.866
distinguishing machine screws from cap
00:42:44.866 --> 00:42:46.891
screws based on the presence of a washer
00:42:46.891 --> 00:42:47.884
phase or its equivalent on the underside
00:42:47.884 --> 00:42:49.200
of the head. And this came from the
00:42:49.200 --> 00:42:51.609
heads and threads vs. United States
00:42:51.609 --> 00:42:55.407
court case in 1969 which said that a
00:42:55.407 --> 00:42:58.226
hexagon head cap screw is this a gradual
00:42:58.226 --> 00:43:04.283
from screws by the presence of a washer
00:43:04.283 --> 00:43:06.304
phase which is in a Boston circle which
00:43:06.304 --> 00:43:10.516
is also called a boss and you can see it
00:43:10.516 --> 00:43:12.479
right here under the head of this screw,
00:43:12.479 --> 00:43:14.506
it is that little raised circle under
00:43:14.506 --> 00:43:15.504
there, that would be a washer phase. It
00:43:15.504 --> 00:43:18.625
can have a washer phase or its
00:43:18.625 --> 00:43:23.460
equivalent and there are two of those,
00:43:23.460 --> 00:43:24.458
the hexagon screw can have chamfered
00:43:24.458 --> 00:43:26.490
corners on the underside of the head and
00:43:26.490 --> 00:43:30.178
you can see examples here of the
00:43:30.178 --> 00:43:32.229
chamfered corners and they are softened
00:43:32.229 --> 00:43:39.468
here so the points of the hex head do
00:43:39.468 --> 00:43:41.490
not gouge into whatever you are
00:43:41.490 --> 00:43:43.428
fastening into. And the other equivalent
00:43:43.428 --> 00:43:48.241
would be a phalange or washer head that
00:43:48.241 --> 00:43:54.175
is attached on the screw that would be
00:43:54.175 --> 00:43:57.855
considered also a washer head
00:43:57.855 --> 00:43:59.378
equivalent. The purpose of a washer
00:43:59.378 --> 00:44:01.821
phase is to give the fastener a smooth
00:44:01.821 --> 00:44:02.828
bearing service the prevalent the points
00:44:02.828 --> 00:44:10.581
of the fastener head to affect the work
00:44:10.581 --> 00:44:12.574
that they are being fastened into. So
00:44:12.574 --> 00:44:14.598
with these attributes it would not be
00:44:14.598 --> 00:44:24.661
classified as a machine screw. ICA
00:44:24.661 --> 00:44:27.444
question, how do they differ from
00:44:27.444 --> 00:44:35.188
structural bolts that have a washer
00:44:35.188 --> 00:44:39.209
phase? Structural bolts are generally
00:44:39.209 --> 00:44:42.202
much larger and sturdier bolt than a
00:44:42.202 --> 00:44:46.514
machine screw which tend to be finer and
00:44:46.514 --> 00:44:52.511
actually they have those measurement
00:44:52.511 --> 00:44:54.982
requirements, so I don't have another
00:44:54.982 --> 00:45:00.039
example. I would have to think if I can
00:45:00.039 --> 00:45:04.798
come up with another example there.
00:45:04.798 --> 00:45:08.225
But, here is an example from a
00:45:08.225 --> 00:45:10.594
headquarters ruling that I wanted to
00:45:10.594 --> 00:45:15.266
mention, this has a hex head with a
00:45:15.266 --> 00:46:08.718
phalange head, but there are serrations
00:46:08.718 --> 00:46:09.717
on the underside of the flange. Because
00:46:09.717 --> 00:46:11.712
those serrations prevent this fastener
00:46:11.712 --> 00:46:13.712
from having a smooth bearing surface
00:46:13.712 --> 00:46:14.739
under the head, it is not considered a
00:46:14.739 --> 00:46:16.738
washer phase equivalent and this example
00:46:16.738 --> 00:46:27.432
was classified as a machine screw.
00:46:27.432 --> 00:46:28.463
Duds are defined as dreaded fasteners
00:46:28.463 --> 00:46:32.455
with one and anchored or fixed in place
00:46:32.455 --> 00:46:34.449
to provide a projection to which
00:46:34.449 --> 00:46:40.087
something may be attached by a nut or
00:46:40.087 --> 00:46:41.099
other fastener. They can be threaded at
00:46:41.099 --> 00:46:46.096
each end, they can be fully threaded or
00:46:46.096 --> 00:46:47.089
they can have ahead. They can also not
00:46:47.089 --> 00:46:50.086
be bent as long as they meet this above
00:46:50.086 --> 00:46:52.078
definition. This is a hanger bolt and
00:46:52.078 --> 00:46:55.222
you can see this one and has wood screw
00:46:55.222 --> 00:47:00.429
threading and at the other and it has
00:47:00.429 --> 00:47:01.423
machine threading here. So, when the
00:47:01.423 --> 00:47:06.618
hanger bolt is fixed in place, this
00:47:06.618 --> 00:47:07.634
machine threading section extends out and
00:47:07.634 --> 00:47:10.620
allows for something to be attached with
00:47:10.620 --> 00:47:19.443
the use of a nut. And this ribbed neck
00:47:19.443 --> 00:47:20.827
is what allows the fastener to be
00:47:20.827 --> 00:47:25.663
anchored in place and then once that is
00:47:25.663 --> 00:47:27.641
anchored, this threaded projection
00:47:27.641 --> 00:47:39.024
allows for a nut to be attached.
00:47:39.024 --> 00:47:59.581
There are several anti-dumping and
00:47:59.581 --> 00:48:05.671
countervailing duty cases four threaded
00:48:05.671 --> 00:48:06.634
rods from China, India, Thailand and
00:48:06.634 --> 00:48:08.794
Taiwan. So, if you have an article
00:48:08.794 --> 00:48:33.434
classified as a stud from any of these
00:48:33.434 --> 00:48:39.423
countries, check to see if any of these
00:48:39.423 --> 00:48:39.425
cases apply.
00:48:39.425 --> 00:48:49.275
There is a question in the box, what is
00:48:49.275 --> 00:48:55.497
considered a preformed hole for
00:48:55.497 --> 00:48:57.505
classification purposes? I do not
00:48:57.505 --> 00:48:59.513
really understand that, a whole is not
00:48:59.513 --> 00:49:00.510
classified, it would just be the whole
00:49:00.510 --> 00:49:03.480
like if you are trying to put a wood
00:49:03.480 --> 00:49:05.480
screw into a piece of wood and they put
00:49:05.480 --> 00:49:07.068
a little pilot hole in so that the
00:49:07.068 --> 00:49:12.057
fastener has thread to thread into it,
00:49:12.057 --> 00:49:14.223
that would be the preformed hole that I
00:49:14.223 --> 00:49:16.039
am talking about. If I am missing the
00:49:16.039 --> 00:49:25.912
question, if you can let me know again
00:49:25.912 --> 00:49:26.899
and clarify that. And the next question
00:49:26.899 --> 00:49:30.092
is when you see a description of screws
00:49:30.092 --> 00:49:31.121
like M4 or M5, does not give you any help
00:49:31.121 --> 00:49:33.115
to the thread diameter measurement?
00:49:33.115 --> 00:49:35.814
Yes. That does, that is a metric and
00:49:35.814 --> 00:49:39.437
there is a table that you can look up to
00:49:39.437 --> 00:49:47.458
see what the diameter is of a M4 or M5
00:49:47.458 --> 00:49:52.404
or M6 and same thing for a 3/8 inch
00:49:52.404 --> 00:49:56.407
screw, yes, I would say I believe the 3/8
00:49:56.407 --> 00:50:00.422
inch is the diameter of that. Again,
00:50:00.422 --> 00:50:06.836
that is really more in the
00:50:06.836 --> 00:50:07.833
distinguishing bolts from screws section,
00:50:07.833 --> 00:50:15.629
so I believe that is correct. but it is
00:50:15.629 --> 00:50:27.506
not included in here.
00:50:27.506 --> 00:50:31.472
The next question is if something is
00:50:31.472 --> 00:50:33.489
imported with fasteners usually not
00:50:33.489 --> 00:50:34.857
known or shown on an invoice but may be
00:50:34.857 --> 00:50:36.891
subject to dumping, would they be
00:50:36.891 --> 00:50:43.280
required to separated out and declared
00:50:43.280 --> 00:50:44.258
separately? And you give me an example
00:50:44.258 --> 00:50:46.267
of what you're talking about with that
00:50:46.267 --> 00:50:51.823
if it is important with fasteners - so,
00:50:51.823 --> 00:50:53.997
if you are bringing in a kit or
00:50:53.997 --> 00:51:00.302
something and that kit includes the
00:51:00.302 --> 00:51:01.332
fasteners to put it together, the
00:51:01.332 --> 00:51:03.333
fasteners are just included with the
00:51:03.333 --> 00:51:05.439
kit, so I'm trying to think if I am just
00:51:05.439 --> 00:51:08.630
classifying fasteners, what else may be
00:51:08.630 --> 00:51:09.989
included with it that would be required
00:51:09.989 --> 00:51:16.607
to be separated out and declared? Okay,
00:51:16.607 --> 00:51:27.826
so furniture or other items that need
00:51:27.826 --> 00:51:34.612
assembly. Yes, so it would not be
00:51:34.612 --> 00:51:36.608
classified by the fasteners if you are
00:51:36.608 --> 00:51:38.609
importing furniture and it includes the
00:51:38.609 --> 00:51:39.602
fasteners, you'd be classifying it by the
00:51:39.602 --> 00:51:41.606
furniture, not by the fasteners. So, we
00:51:41.606 --> 00:51:42.880
would not have to separate those out -
00:51:42.880 --> 00:51:46.804
are you saying if I am bringing in
00:51:46.804 --> 00:51:50.878
furniture and the fastener has
00:51:50.878 --> 00:51:52.874
anti-dumping? I am sorry, I bet that is
00:51:52.874 --> 00:52:00.681
what you are asking. I don't believe it
00:52:00.681 --> 00:52:01.671
needs to be separated out, I am going to
00:52:01.671 --> 00:52:04.301
have to check on that. I do not believe
00:52:04.301 --> 00:52:08.478
so, but I would like to double check
00:52:08.478 --> 00:52:10.046
that before I give you an official
00:52:10.046 --> 00:52:16.256
answer on that. That is a good
00:52:16.256 --> 00:52:17.252
question. Okay, let me move forward.
00:52:17.252 --> 00:52:21.289
Okay, I want to move along to the other
00:52:21.289 --> 00:52:27.879
subheading under other screws or else and
00:52:27.879 --> 00:52:33.443
there nuts and washers and 73 18.15.60
00:52:33.443 --> 00:52:38.111
includes other goods that are less than
00:52:38.111 --> 00:53:19.916
6 mm in diameter. And the 73 18.15.80
00:53:19.916 --> 00:53:20.919
includes those other goods that are 6 mm
00:53:20.919 --> 00:53:22.919
or more in diameter. So, since the
00:53:22.919 --> 00:53:24.911
difference between these two sections is
00:53:24.911 --> 00:53:27.031
just the diameter, I am going to go
00:53:27.031 --> 00:53:29.218
through these breakouts under 73
00:53:29.218 --> 00:53:32.246
18.15.80 for this presentation. And
00:53:32.246 --> 00:53:43.862
under this section, there are breakouts
00:53:43.862 --> 00:53:51.328
for set roots, socket screws and cap
00:53:51.328 --> 00:53:53.325
screws, we have already gone over cap
00:53:53.325 --> 00:54:03.691
and so we will focus on set and socket,
00:54:03.691 --> 00:54:03.693
for now.
00:54:03.693 --> 00:54:05.700
Setscrews are used when one component has
00:54:05.700 --> 00:54:07.702
to be attached within another one
00:54:07.702 --> 00:54:09.701
without any protrusions. So, like if
00:54:09.701 --> 00:54:11.198
you had a year and a shaft assembly, if
00:54:11.198 --> 00:54:16.037
you used a regular hex bolt, the head
00:54:16.037 --> 00:54:19.479
may get in the smooth operation of a
00:54:19.479 --> 00:54:21.474
gear assembly because it sticks out, so
00:54:21.474 --> 00:54:23.516
you would use a set screw that does not
00:54:23.516 --> 00:54:27.254
have a head that sticks out and
00:54:27.254 --> 00:54:32.014
interfere with the operation of the gear.
00:54:32.014 --> 00:54:37.254
Set screws are designed to withstand
00:54:37.254 --> 00:54:39.385
rattling in operation and not come
00:54:39.385 --> 00:54:43.655
undone. They are fully threaded and
00:54:43.655 --> 00:54:45.815
they can be headed or headless and even
00:54:45.815 --> 00:54:51.436
the headless ones has a drive, this one
00:54:51.436 --> 00:54:56.841
has a slotted drive and this one has a
00:54:56.841 --> 00:54:58.836
hex drive. And setscrews have specific
00:54:58.836 --> 00:55:04.029
point designs such as these examples.
00:55:04.029 --> 00:55:09.872
There is a question about internally
00:55:09.872 --> 00:55:11.217
threaded such as opinion, we are going
00:55:11.217 --> 00:55:20.603
to get to the other threaded examples
00:55:20.603 --> 00:55:24.682
shortly. Then, we move on into the other
00:55:24.682 --> 00:55:25.809
breakout under this subheading and at
00:55:25.809 --> 00:55:31.001
the first one is for socket screws, there
00:55:31.001 --> 00:55:35.819
classified under 7813.15.80 30 if it is
00:55:35.819 --> 00:55:45.749
stainless steel and 8030/45 other than
00:55:45.749 --> 00:55:46.746
stainless steel. Socket screws refers to
00:55:46.746 --> 00:55:48.740
fasteners with recessed holes in the
00:55:48.740 --> 00:55:50.751
head, this indentation in the head can
00:55:50.751 --> 00:55:51.733
be in the shape of a hex, a square or
00:55:51.733 --> 00:55:53.765
some other form and they are intended to
00:55:53.765 --> 00:55:54.860
be tightened or loosened with a Alan
00:55:54.860 --> 00:56:00.396
wrench or a hex key as opposed to a
00:56:00.396 --> 00:56:03.029
traditional screwdriver. So, before we
00:56:03.029 --> 00:56:08.076
leave this other screw or bolts
00:56:08.076 --> 00:56:09.074
subheading, I want to mention this other
00:56:09.074 --> 00:56:18.803
example from a headquarters ruling.
00:56:18.803 --> 00:56:20.826
This fastener is called several names,
00:56:20.826 --> 00:56:21.787
it could be called a oil bolt or banjo
00:56:21.787 --> 00:56:23.827
bolt or pressure fitting, as you can see
00:56:23.827 --> 00:56:25.565
it has a hex head, it is threaded,
00:56:25.565 --> 00:56:26.576
hollow and it has this whole through a
00:56:26.576 --> 00:56:28.603
shaft, so a little different than the
00:56:28.603 --> 00:56:30.037
other screws we have been looking at.
00:56:30.037 --> 00:56:32.226
It is used solely in breaking systems of
00:56:32.226 --> 00:56:34.258
motor vehicles and it functions, the
00:56:34.258 --> 00:56:39.443
screw functions to attach the oil feed
00:56:39.443 --> 00:56:41.047
line and this whole functions to allow
00:56:41.047 --> 00:56:48.267
brake fluid through the hole into the
00:56:48.267 --> 00:56:50.264
stem. So, according to the importer,
00:56:50.264 --> 00:56:52.278
the brake system would not be functional
00:56:52.278 --> 00:56:55.854
without the passage of brake fluid.
00:56:55.854 --> 00:56:57.820
Now, clearly this item has two
00:56:57.820 --> 00:57:02.063
significant functions. It functions as
00:57:02.063 --> 00:57:04.056
a screw, and it allows the flow of brake
00:57:04.056 --> 00:57:20.334
fluid, so where do we classify it? Is
00:57:20.334 --> 00:57:21.330
it a fastener of 7813 or a part of motor
00:57:21.330 --> 00:57:24.465
vehicles in chapter 87? The
00:57:24.465 --> 00:57:29.671
explanatory notes state that 7813
00:57:29.671 --> 00:57:30.666
includes all types of fastening bolts
00:57:30.666 --> 00:57:32.222
and metal screws regardless of shape and
00:57:32.222 --> 00:57:36.612
use. So, this item does have a
00:57:36.612 --> 00:57:43.086
fastening function, because the threaded
00:57:43.086 --> 00:57:45.112
portion here secures tubes, hoses or
00:57:45.112 --> 00:57:47.121
lines in the braking system. Because it
00:57:47.121 --> 00:57:49.114
has a fastening function, it can be
00:57:49.114 --> 00:57:55.723
classified as a screw under 7813.15 E,
00:57:55.723 --> 00:57:56.722
because it can be classified under 7813,
00:57:56.722 --> 00:57:58.711
it is considered a part of general use
00:57:58.711 --> 00:58:02.245
as we talked about at the beginning.
00:58:02.245 --> 00:58:06.873
Parts of general use, when they are
00:58:06.873 --> 00:58:07.891
entered separately are not considered as
00:58:07.891 --> 00:58:09.884
parts of articles, but are classified in
00:58:09.884 --> 00:58:11.877
the appropriate heading under section 15
00:58:11.877 --> 00:58:19.315
and in this case, the appropriate
00:58:19.315 --> 00:58:21.326
heading would be 7813.15.80 as a screw.
00:58:21.326 --> 00:58:23.324
And also parts of general use are
00:58:23.324 --> 00:58:24.316
excluded from general use classification
00:58:24.316 --> 00:58:28.312
by section 17 note 2B and that is where
00:58:28.312 --> 00:58:35.129
we would classify a part of a motor
00:58:35.129 --> 00:58:37.133
vehicle. And so even this oil bolt may
00:58:37.133 --> 00:58:38.126
be specifically designed for use in motor
00:58:38.126 --> 00:58:40.131
vehicles or motorcycles, it is
00:58:40.131 --> 00:58:42.844
nevertheless still a screw which would
00:58:42.844 --> 00:58:45.002
be classifiable in heading 7813 and the
00:58:45.002 --> 00:58:49.089
fact that the oil bolt also allows for
00:58:49.089 --> 00:58:51.110
the passage of fluids does not negate
00:58:51.110 --> 00:58:52.712
the fact that it has a significant
00:58:52.712 --> 00:58:56.482
fastening function. Are there any
00:58:56.482 --> 00:59:09.420
questions on that before I move on?
00:59:09.420 --> 00:59:15.216
Okay, 7813.16 provides for nuts. And
00:59:15.216 --> 00:59:19.311
classified under this subheading from
00:59:19.311 --> 00:59:20.274
China are subject to 301 trade remedy
00:59:20.274 --> 00:59:22.902
than all other fasteners of 7813.
00:59:22.902 --> 00:59:29.654
Currently nuts from China are subject to
00:59:29.654 --> 00:59:30.647
an additional 7.5% trade remedies whereas
00:59:30.647 --> 00:59:32.016
all the other fasteners are subject to
00:59:32.016 --> 00:59:37.037
an additional 25% trade remedies.
00:59:37.037 --> 00:59:45.527
The subheading for nuts is broken into
00:59:45.527 --> 00:59:46.552
two headings, lug nuts and other nuts, if
00:59:46.552 --> 00:59:48.545
it is not a lug nut, it would be
00:59:48.545 --> 00:59:49.546
classified under the subheading of
00:59:49.546 --> 00:59:52.082
other, so let's take a look at what a
00:59:52.082 --> 00:59:55.281
lug nut is.
00:59:55.281 --> 00:59:57.285
Lug nuts are designed to hold a wheel
00:59:57.285 --> 01:00:02.243
onto a vehicle. They interface with the
01:00:02.243 --> 01:00:06.052
design of the wheel and many of them
01:00:06.052 --> 01:00:08.428
have a conical or tapered seat, because
01:00:08.428 --> 01:00:13.268
of that. The statistical breakouts
01:00:13.268 --> 01:00:14.267
associated with lug nuts are nonblocking
01:00:14.267 --> 01:00:17.216
chrome plated lug nuts which are in
01:00:17.216 --> 01:00:21.031
7813. 16.0015 and then you have locking
01:00:21.031 --> 01:00:24.213
lug nuts which in in 30 and other lug
01:00:24.213 --> 01:00:35.787
nuts which ends in 45.
01:00:35.787 --> 01:00:37.791
Other nuts of stainless steel are
01:00:37.791 --> 01:00:40.504
provided for in 7813.16.00 60 and other
01:00:40.504 --> 01:00:44.515
nuts that are not stainless steel are
01:00:44.515 --> 01:00:51.208
provided for in 7813.16.00 85. This is
01:00:51.208 --> 01:00:53.205
defined broadly as a type of fastener
01:00:53.205 --> 01:00:54.184
that is internally threaded and often,
01:00:54.184 --> 01:00:56.199
but not always used opposite a meeting
01:00:56.199 --> 01:01:00.221
bolt. It holds the bolt in place and
01:01:00.221 --> 01:01:03.450
fastens materials together. Nuts are
01:01:03.450 --> 01:01:08.312
usually happen throughout and some
01:01:08.312 --> 01:01:10.857
examples include a common nut, this is a
01:01:10.857 --> 01:01:17.862
castle nut, a wingnut, a square nut and
01:01:17.862 --> 01:01:19.869
a clinch. In these examples, the nut is
01:01:19.869 --> 01:01:21.654
torqued onto the meeting bolt, but that
01:01:21.654 --> 01:01:23.446
does not appear to be a requirement.
01:01:23.446 --> 01:01:29.265
Two examples of that.
01:01:29.265 --> 01:01:31.885
Both of these examples are internally
01:01:31.885 --> 01:01:34.467
threaded and they function to hold a
01:01:34.467 --> 01:01:36.476
bolt in place and thereby fasten
01:01:36.476 --> 01:01:39.664
materials together. But, in both of
01:01:39.664 --> 01:01:43.258
these examples, the nut is not torqued
01:01:43.258 --> 01:01:45.035
onto the bowl, instead, in each case,
01:01:45.035 --> 01:01:47.036
the nut is placed in the material that
01:01:47.036 --> 01:01:50.215
it will fasten and then it provides a
01:01:50.215 --> 01:01:52.863
threaded receptacle for the bolt that is
01:01:52.863 --> 01:01:54.903
then fastened into the nut, so they are
01:01:54.903 --> 01:01:56.641
a little bit different than a
01:01:56.641 --> 01:02:00.452
traditional nut, but they fit into the
01:02:00.452 --> 01:02:03.685
router definition which is again a type
01:02:03.685 --> 01:02:05.675
of fastener internally threaded and
01:02:05.675 --> 01:02:08.887
often used opposite a meeting bolt
01:02:08.887 --> 01:02:10.675
holding the bolt in place and thus
01:02:10.675 --> 01:02:19.215
fastening the materials together.
01:02:19.215 --> 01:02:23.817
Pipefitting nuts are not nuts of heading
01:02:23.817 --> 01:02:27.259
7813, they have different features and
01:02:27.259 --> 01:02:32.857
intended usages and groups and they are
01:02:32.857 --> 01:02:35.311
marketed in different apartments and not
01:02:35.311 --> 01:02:42.058
classified in 7813.
01:02:42.058 --> 01:02:52.469
The question is, what a flat cushion not
01:02:52.469 --> 01:02:54.664
be other or Push cap? I would need to
01:02:54.664 --> 01:03:03.258
look at what a flat push not is to answer
01:03:03.258 --> 01:03:05.286
that question. 7813.19 provides other
01:03:05.286 --> 01:03:26.505
articles that are similar to 7813 but
01:03:26.505 --> 01:03:28.512
that are not covered by the previous
01:03:28.512 --> 01:03:30.459
subheadings. So, here are some examples.
01:03:30.459 --> 01:03:35.217
A hollow wall anchor or a Molly bolt
01:03:35.217 --> 01:03:38.819
has a machine screw here, it is within a
01:03:38.819 --> 01:03:41.667
separate T shaped anchor with an
01:03:41.667 --> 01:03:44.226
internally threaded hollow barrel shaped
01:03:44.226 --> 01:03:47.621
them. So, the Molly bolt is inserted
01:03:47.621 --> 01:03:50.650
into a predrilled hole where it is
01:03:50.650 --> 01:03:52.016
hammered in place and a drill or
01:03:52.016 --> 01:03:54.695
screwdriver is used to tighten the screw
01:03:54.695 --> 01:04:01.426
expands the anchor into the wall. Once
01:04:01.426 --> 01:04:07.763
the anchor is secure, the screw is
01:04:07.763 --> 01:04:08.765
removed and the screw only functions to
01:04:08.765 --> 01:04:10.767
expand that anchor and then they take it
01:04:10.767 --> 01:04:12.238
out. Once the Molly bolt is in place,
01:04:12.238 --> 01:04:16.049
you can use the anchor to hang heavier
01:04:16.049 --> 01:04:19.862
items on the wall. So, this item is not
01:04:19.862 --> 01:04:25.091
a bolt, because it is not designed for
01:04:25.091 --> 01:04:27.111
assembly with a nut, it is not a screw,
01:04:27.111 --> 01:04:29.659
because it does not mate with a
01:04:29.659 --> 01:04:30.683
preformed internal thread or form its own
01:04:30.683 --> 01:04:33.425
thread and it is not a study, because it
01:04:33.425 --> 01:04:36.865
does not have anything protruding that
01:04:36.865 --> 01:04:42.049
can support another object, so it is
01:04:42.049 --> 01:04:49.417
classified as 7813.19 as a other threaded
01:04:49.417 --> 01:04:50.429
article.
01:04:50.429 --> 01:04:57.267
And my other example is the eye lag
01:04:57.267 --> 01:05:02.485
screw, this would be screwed into the
01:05:02.485 --> 01:05:04.487
ceiling, so that a suspended acoustical
01:05:04.487 --> 01:05:10.509
ceiling panel can be secured by wires
01:05:10.509 --> 01:05:11.535
included through the eye here. This is
01:05:11.535 --> 01:05:13.529
not a screw, because it does not have a
01:05:13.529 --> 01:05:21.195
slotted or recessed head and it does not
01:05:21.195 --> 01:05:23.225
provide an additional function that is
01:05:23.225 --> 01:05:24.192
not associated with screws. It is not a
01:05:24.192 --> 01:05:26.218
screw hook or ring because it is not
01:05:26.218 --> 01:05:28.226
bent at a right angle and it is not a
01:05:28.226 --> 01:05:31.050
study, because the eye cannot mate an
01:05:31.050 --> 01:05:32.547
attachment with a nut or other fastener,
01:05:32.547 --> 01:05:37.257
therefore it is classified under
01:05:37.257 --> 01:05:40.098
7813.19. There is a question, is a stud
01:05:40.098 --> 01:05:51.065
bolt a bolt or a Stud bolt? A stud is
01:05:51.065 --> 01:05:54.066
technically a type of bolt, but it has a
01:05:54.066 --> 01:06:03.398
particular - it needs to be fastened
01:06:03.398 --> 01:06:04.386
into a material and have something
01:06:04.386 --> 01:06:06.398
protruding out that you can attach a nut
01:06:06.398 --> 01:06:08.373
or other fastener too. So, if it meets
01:06:08.373 --> 01:06:09.373
that definition, then it would be
01:06:09.373 --> 01:06:11.373
classified as a stud, but I would need
01:06:11.373 --> 01:06:12.805
to see the item that you are specifically
01:06:12.805 --> 01:06:22.288
asking about.
01:06:22.288 --> 01:06:23.288
Lastly we are getting into the
01:06:23.288 --> 01:06:28.309
non-threaded subheadings. This
01:06:28.309 --> 01:06:32.091
subheading breaks out into two different
01:06:32.091 --> 01:06:33.350
types of washers. 73 18.21 provides for
01:06:33.350 --> 01:06:40.905
spring washers and other lock washers and
01:06:40.905 --> 01:06:42.943
7813.22 provides for other washers and
01:06:42.943 --> 01:06:44.935
so before the differences, I will cover
01:06:44.935 --> 01:06:47.064
the attributes of washers in general.
01:06:47.064 --> 01:06:49.089
In general, washers are usually small,
01:06:49.089 --> 01:06:51.703
thin discs with a hole in the center and
01:06:51.703 --> 01:06:53.709
their place between unknot and one of
01:06:53.709 --> 01:06:56.275
the parts to be fixed in place to
01:06:56.275 --> 01:06:57.437
increase the bearing surface of a
01:06:57.437 --> 01:06:59.631
threaded fastener. Washers function to
01:06:59.631 --> 01:07:03.255
protect the part or the material that is
01:07:03.255 --> 01:07:05.258
being fastened and it evenly distributes
01:07:05.258 --> 01:07:11.466
the weight when you're tightening. So,
01:07:11.466 --> 01:07:13.475
helical spring lock washers are designed
01:07:13.475 --> 01:07:15.640
to keep the fastener from loosening.
01:07:15.640 --> 01:07:17.051
They have this split which gives them the
01:07:17.051 --> 01:07:20.866
flexibility and they are also used to
01:07:20.866 --> 01:07:24.271
prevent fastening or loosening due to
01:07:24.271 --> 01:07:25.262
vibrations. The helical spring lock
01:07:25.262 --> 01:07:28.075
washers from China and Taiwan may be
01:07:28.075 --> 01:07:36.915
subject to these antidumping cases.
01:07:36.915 --> 01:07:37.911
Other spring and lock washers are
01:07:37.911 --> 01:07:40.435
provided for in 7813.22.00 90. As you
01:07:40.435 --> 01:07:46.475
would expect, locking washers prevent
01:07:46.475 --> 01:07:47.437
loosening by preventing unscrewing
01:07:47.437 --> 01:07:49.475
rotation of the fastening device. There
01:07:49.475 --> 01:07:52.490
are several types of lock washers
01:07:52.490 --> 01:07:53.239
including this example as an internal
01:07:53.239 --> 01:07:58.827
lock washer and external lock washer,
01:07:58.827 --> 01:08:05.275
conical spring washers and wedge lock
01:08:05.275 --> 01:08:19.662
washers.
01:08:19.662 --> 01:08:20.689
And let's see here - 7813.22 provides for
01:08:20.689 --> 01:08:23.844
other washers and examples of washers
01:08:23.844 --> 01:08:28.491
that are classified here are flat
01:08:28.491 --> 01:08:32.197
washers, finishing, tender, square or
01:08:32.197 --> 01:08:42.173
ogee washers.
01:08:42.173 --> 01:08:43.165
Rivets are used for the permanent
01:08:43.165 --> 01:08:45.184
assembly of metal parts when reliability
01:08:45.184 --> 01:08:47.189
and safety are important. They are not
01:08:47.189 --> 01:08:48.187
threaded and usually cylindrical in
01:08:48.187 --> 01:08:50.176
shape. They are installed by using a
01:08:50.176 --> 01:08:51.293
hammer or a rivet gun and that hammer or
01:08:51.293 --> 01:08:55.683
rivet gun would form this headless and.
01:08:55.683 --> 01:08:58.716
7813.23 includes solid rivets which
01:08:58.716 --> 01:09:05.251
have a solid shaft on one end and it
01:09:05.251 --> 01:09:07.858
includes tubular rivets which are partly
01:09:07.858 --> 01:09:09.898
hollow and you can partly see that in
01:09:09.898 --> 01:09:12.076
the picture, it is only partly hollow
01:09:12.076 --> 01:09:17.641
and then it gets solid there. But, this
01:09:17.641 --> 01:09:18.823
heading excludes tubular rivets that
01:09:18.823 --> 01:09:21.945
have a deep hole, it excludes bifurcated
01:09:21.945 --> 01:09:28.116
which are split and it includes break
01:09:28.116 --> 01:09:30.487
mandrel rivets, those are all classified
01:09:30.487 --> 01:09:32.651
in 8308.
01:09:32.651 --> 01:09:38.506
Here are those rivets. You have got a
01:09:38.506 --> 01:09:40.501
tubular rivet which is also known as a
01:09:40.501 --> 01:09:44.156
hollow rivet, they have a hollow shank.
01:09:44.156 --> 01:09:45.148
This is a bifurcated rivets, it is also
01:09:45.148 --> 01:09:48.378
known as a split rivet, they are pretty
01:09:48.378 --> 01:09:50.368
split along the length of the shaft and
01:09:50.368 --> 01:09:53.284
that forms these two legs and these
01:09:53.284 --> 01:09:54.838
rivets usually require special tools for
01:09:54.838 --> 01:09:58.699
installation. And then you have blind
01:09:58.699 --> 01:10:03.538
rivets which are also known as break
01:10:03.538 --> 01:10:04.530
stemming rivets or break mandrel rivets
01:10:04.530 --> 01:10:06.539
or pop rivets, these are tubular
01:10:06.539 --> 01:10:08.533
fasteners and have a mandrel through the
01:10:08.533 --> 01:10:09.528
center. And I also want to point out
01:10:09.528 --> 01:10:11.878
that these rivets that are classified in
01:10:11.878 --> 01:10:16.268
8308 are also subject to 301 trade
01:10:16.268 --> 01:11:17.916
remedies if they are also from China.
01:11:17.916 --> 01:11:26.291
It looks like I had a HDS code mistake
01:11:26.291 --> 01:11:33.658
on the last slide here. 20 200 90. I
01:11:33.658 --> 01:11:50.825
don't even know what that was. Sorry
01:11:50.825 --> 01:11:55.063
about that. Okay, so cotters and cotter
01:11:55.063 --> 01:11:59.264
pins are provided for in 7813.24, pins
01:11:59.264 --> 01:12:02.452
are used for fitting in holes, spindles,
01:12:02.452 --> 01:12:06.980
shaft, bolts and they hold parts
01:12:06.980 --> 01:12:08.518
together and this one is a split pin, a
01:12:08.518 --> 01:12:19.466
hairpin and a bowtie. A cotter is a
01:12:19.466 --> 01:12:21.452
wedge, a pin or a key that is inserted
01:12:21.452 --> 01:12:23.450
through a slot or passes through a hole
01:12:23.450 --> 01:12:24.695
or fits into a groove or a slot that cuts
01:12:24.695 --> 01:12:26.694
around a shaft. They have a similar
01:12:26.694 --> 01:12:28.111
function of holding parts together like a
01:12:28.111 --> 01:12:29.854
cotter pin, but they are usually bigger
01:12:29.854 --> 01:12:35.063
and sturdier and some examples of those
01:12:35.063 --> 01:12:42.260
would be paper pins, axle keys and
01:12:42.260 --> 01:12:43.260
Woodruff keys.
01:12:43.260 --> 01:12:50.357
Cirque clips are also placed under
01:12:50.357 --> 01:12:51.321
7813.24 and used to prevent lateral
01:12:51.321 --> 01:12:53.361
movement and they can be really simple
01:12:53.361 --> 01:12:55.504
with a gap to more complex shapes and
01:12:55.504 --> 01:13:02.886
some of these include this one is a
01:13:02.886 --> 01:13:03.904
internal or slightly open circlips and
01:13:03.904 --> 01:13:18.287
this one is a E hype circlips.
01:13:18.287 --> 01:13:21.898
Non-threaded fasteners that are not
01:13:21.898 --> 01:13:25.237
classifiable under the previous
01:13:25.237 --> 01:13:34.815
subheadings are classifiable in 7813.29.
01:13:34.815 --> 01:13:36.799
The cleavage pain is an example and
01:13:36.799 --> 01:13:38.832
here are two different examples of one,
01:13:38.832 --> 01:13:40.797
it performs a fashioning function, it is
01:13:40.797 --> 01:13:44.594
not threaded, but it is not a washer or
01:13:44.594 --> 01:13:46.584
a rivet or a cotter or a cotter pin, so
01:13:46.584 --> 01:13:47.609
it will go under a non-threaded fastener
01:13:47.609 --> 01:14:14.689
and just as an example, here is a clevis
01:14:14.689 --> 01:14:18.094
pin through the center here and actually
01:14:18.094 --> 01:14:26.109
this is a cotter pin here that holds the
01:14:26.109 --> 01:14:28.128
clevis in place. Pension pins would be
01:14:28.128 --> 01:14:34.368
for another example of non-threaded
01:14:34.368 --> 01:14:35.379
fasteners and they are hollow and slotted
01:14:35.379 --> 01:14:37.366
and the diameter is a little bit bigger
01:14:37.366 --> 01:14:39.154
than the diameter it will go into and
01:14:39.154 --> 01:14:41.146
once it is installed it pushes against
01:14:41.146 --> 01:14:47.303
the perimeter to secure it in place.
01:14:47.303 --> 01:14:54.092
This top example is a steel bolt that has
01:14:54.092 --> 01:14:56.098
two flattened sections on opposite side
01:14:56.098 --> 01:14:58.079
of the shank, so because the threading
01:14:58.079 --> 01:14:58.854
is flattened, the threading does not form
01:14:58.854 --> 01:15:04.060
a helix and therefore not considered a
01:15:04.060 --> 01:15:08.695
threaded fastener. A speed not on the
01:15:08.695 --> 01:15:09.685
bottom here is used on threaded
01:15:09.685 --> 01:15:13.160
fasteners, but it cannot be classified
01:15:13.160 --> 01:15:15.164
as a nut, because it does not have a
01:15:15.164 --> 01:15:17.176
complete thread in here, so it is
01:15:17.176 --> 01:15:26.702
classified here as a other non-threaded
01:15:26.702 --> 01:15:27.702
fastener. There
01:15:27.702 --> 01:15:29.712
is a informed compliance publication
01:15:29.712 --> 01:15:30.703
that provides guidance on the fasteners
01:15:30.703 --> 01:15:34.502
of 7813 that you can also reference in
01:15:34.502 --> 01:15:35.496
addition to this slide deck and just to
01:15:35.496 --> 01:15:38.005
let you know we are currently updating
01:15:38.005 --> 01:15:42.280
that ICP.
01:15:42.280 --> 01:15:47.063
So, that is all I have for you. Before I
01:15:47.063 --> 01:15:53.719
get into questions, I just want to thank
01:15:53.719 --> 01:15:55.709
my associate, Richard Schueler for his
01:15:55.709 --> 01:15:57.716
help on this presentation and also the
01:15:57.716 --> 01:16:33.249
webinar team that made this
01:16:33.249 --> 01:16:34.244
electronically possible and that is
01:16:34.244 --> 01:17:21.871
Sandra Walia, Fung King Kong, Amy
01:17:21.871 --> 01:17:28.915
Purkett (SP?) and Lynn Banks. Contact
01:17:28.915 --> 01:17:29.910
information for Richard and me is on the
01:17:29.910 --> 01:17:35.755
screen if you have questions outside of
01:17:35.755 --> 01:17:38.313
this forum, you can reach out to us at
01:17:38.313 --> 01:17:40.315
these email addresses. And with that,
01:17:40.315 --> 01:17:46.662
do you have any questions for me?
01:17:46.662 --> 01:17:54.490
Okay, I am seeing a couple - let me get
01:17:54.490 --> 01:18:04.498
to where I can see - I lost my chat
01:18:04.498 --> 01:18:08.852
here, sorry about that, let me get it
01:18:08.852 --> 01:18:23.526
back. Okay, sorry, I am trying to get
01:18:23.526 --> 01:18:26.711
where I saw a number of one's where you
01:18:26.711 --> 01:18:31.199
wanted to see certain pages, let me get
01:18:31.199 --> 01:18:42.240
back there. Okay, my thumbnails are not
01:18:42.240 --> 01:18:48.665
showing up here. Okay - okay, let's go
01:18:48.665 --> 01:18:50.888
with there were a number of pages that
01:18:50.888 --> 01:18:56.750
we wanted to go back to and I am just
01:18:56.750 --> 01:18:59.217
going to go where I see those slides,
01:18:59.217 --> 01:19:15.529
33. I also see a slide nine.
01:19:15.529 --> 01:19:17.495
>>SPEAKER: There is also 22 and 38
01:19:17.495 --> 01:19:18.499
they have requested.
01:19:18.499 --> 01:19:20.519
>>JENNIFER JAMESON: Thank you, here
01:19:20.519 --> 01:19:45.448
is 22. Here is 38. I just saw 39.
01:19:45.448 --> 01:19:52.494
>>SPEAKER: Also, do articles of 7813
01:19:52.494 --> 01:19:56.108
require an import steel license
01:19:56.108 --> 01:19:56.109
permit?
01:19:56.109 --> 01:20:10.558
>>JENNIFER JAMESON: import steel
01:20:10.558 --> 01:20:12.532
license permit - I do not think so. I
01:20:12.532 --> 01:20:14.537
have not worked with one of those, so I
01:20:14.537 --> 01:20:21.699
would say no. Thank you, Ed, who thought
01:20:21.699 --> 01:20:23.701
my presentation was riveting and did my
01:20:23.701 --> 01:20:26.252
basic training years ago! I am seeing
01:20:26.252 --> 01:20:43.692
slide 11 and a question. And 42. And
01:20:43.692 --> 01:20:51.282
43.
01:20:51.282 --> 01:20:54.864
>>SPEAKER: There is also a question,
01:20:54.864 --> 01:20:57.409
what a linchpin considered the same as a
01:20:57.409 --> 01:20:57.410
cotter and?
01:20:57.410 --> 01:21:04.502
>>JENNIFER JAMESON: I would have to
01:21:04.502 --> 01:21:05.498
see what a linchpin looks like that you
01:21:05.498 --> 01:21:08.902
are talking about the answer that if you
01:21:08.902 --> 01:21:10.926
want to email me separately, I can take
01:21:10.926 --> 01:21:19.281
a look at it. Our rivets that are
01:21:19.281 --> 01:21:22.867
threaded still considered rivets and
01:21:22.867 --> 01:21:35.179
under what classification, 73 or 83 ? I
01:21:35.179 --> 01:21:37.722
would need to see what rivet you are
01:21:37.722 --> 01:21:41.535
talking about, if it has a fastening
01:21:41.535 --> 01:21:48.744
function - I would need to see it, I am
01:21:48.744 --> 01:21:54.371
sorry. Yes, I cover the difference
01:21:54.371 --> 01:21:59.778
between a screw and a bolt and that was
01:21:59.778 --> 01:22:06.424
early on, I would guess around here and
01:22:06.424 --> 01:22:17.315
let me find it - here is the difference
01:22:17.315 --> 01:22:18.315
between bolts and screws, this is a basic
01:22:18.315 --> 01:22:21.318
overview, you should look at the
01:22:21.318 --> 01:22:22.860
distinguishing bolts from screws ICP for
01:22:22.860 --> 01:22:27.468
the specifics, because if the fastener
01:22:27.468 --> 01:22:28.493
has more characteristics of a screw, then
01:22:28.493 --> 01:22:33.510
it will be a screw. There is a
01:22:33.510 --> 01:22:41.270
question, are speed nets also known as a
01:22:41.270 --> 01:22:44.058
Steel clip? I believe they are. I have
01:22:44.058 --> 01:23:00.110
a IOR claimed as a bolt used as a spare
01:23:00.110 --> 01:23:05.323
part on a helicopter is 8803, but it is
01:23:05.323 --> 01:23:06.317
just a regular part, only more
01:23:06.317 --> 01:23:08.324
expensive, absolutely 7813. If they can
01:23:08.324 --> 01:23:16.740
meet the definition of a bolt or any
01:23:16.740 --> 01:23:17.717
fastener in 7813, and it is coming in by
01:23:17.717 --> 01:23:19.737
itself, it would be classified under
01:23:19.737 --> 01:23:24.867
7813, absolutely. I am seeing slide 47.
01:23:24.867 --> 01:23:40.394
There is a question if a hardware kit
01:23:40.394 --> 01:23:42.400
is imported separately with multiple
01:23:42.400 --> 01:23:43.745
washers, nuts, bolts of different sizes,
01:23:43.745 --> 01:23:46.463
do we need to classify each item in the
01:23:46.463 --> 01:23:52.362
kit separately? So, I think then we are
01:23:52.362 --> 01:23:58.091
going to have to look at is a going to
01:23:58.091 --> 01:24:01.523
be a set for Terrace purposes and if it
01:24:01.523 --> 01:24:04.086
is, if for example it is a hardware kit
01:24:04.086 --> 01:24:06.059
to put together a specific piece of
01:24:06.059 --> 01:24:07.540
furniture, then we can go by what is the
01:24:07.540 --> 01:24:10.854
essential character of the set, so maybe
01:24:10.854 --> 01:24:15.087
there is you know 30 bolts and two
01:24:15.087 --> 01:24:17.494
washers, it would be classified by that
01:24:17.494 --> 01:24:22.082
bolt. Or it could be classified by
01:24:22.082 --> 01:24:23.478
tariff if they are all equally important.
01:24:23.478 --> 01:24:27.120
If it is not a set, then yes, you will
01:24:27.120 --> 01:24:36.293
have to classify them all separately. I
01:24:36.293 --> 01:24:41.714
am just going to look through some of
01:24:41.714 --> 01:24:43.705
these. Okay, so there is a pin with a
01:24:43.705 --> 01:24:50.098
little ball mechanism at the bottom, okay
01:24:50.098 --> 01:24:56.940
and she said - he says I used to
01:24:56.940 --> 01:24:57.953
classify them as 8302, a lock mechanism
01:24:57.953 --> 01:24:59.954
without a key, do you have any criteria
01:24:59.954 --> 01:25:10.046
about this? So, a lock of 3302 need
01:25:10.046 --> 01:25:12.067
thick meat or some kind of electronic
01:25:12.067 --> 01:25:14.071
way to open and I don't think that this
01:25:14.071 --> 01:25:16.060
item if I am thinking of the correct
01:25:16.060 --> 01:25:22.744
one would not need one, so I think more
01:25:22.744 --> 01:25:24.736
than likely it will go in 73, but if you
01:25:24.736 --> 01:25:26.759
can send me a picture, I can look at it
01:25:26.759 --> 01:26:02.612
and get you a better answer than that.
01:26:02.612 --> 01:26:03.634
I think I have shown some of these
01:26:03.634 --> 01:26:10.167
slides, but I'm going backwards to
01:26:10.167 --> 01:26:16.304
answer everybody. Slide 14 - I have got
01:26:16.304 --> 01:26:27.507
slide 36 - I do not think I have shown
01:26:27.507 --> 01:26:30.383
57. And again, these slides will be
01:26:30.383 --> 01:26:32.733
available in about 2 to 3 weeks when
01:26:32.733 --> 01:26:50.838
this is posted. Okay, I'm going
01:26:50.838 --> 01:26:52.840
backward and somebody is asking about a
01:26:52.840 --> 01:26:59.902
recording of the webinar, yes it will
01:26:59.902 --> 01:27:01.891
absolutely be available. Okay, so I
01:27:01.891 --> 01:27:03.888
think I have gone through all the
01:27:03.888 --> 01:27:04.895
questions backwards and I will see if
01:27:04.895 --> 01:27:06.897
anything new has come in. A shop class
01:27:06.897 --> 01:27:12.063
for trade nerds, what a hardware kit be
01:27:12.063 --> 01:27:16.508
entered as co-mingled goods? I would
01:27:16.508 --> 01:27:27.450
need more information about that one.
01:27:27.450 --> 01:27:29.438
In 22 used in chapter 90, medical
01:27:29.438 --> 01:27:35.984
equipment, is that still a general use
01:27:35.984 --> 01:27:38.508
fastener? I think it would not, that is
01:27:38.508 --> 01:27:38.995
off the top of my head, I know a
01:27:38.995 --> 01:27:41.859
surgical screw like a dental screw or a
01:27:41.859 --> 01:27:45.961
bone setting screw are classified in 90
01:27:45.961 --> 01:27:49.083
and in those would not be general use,
01:27:49.083 --> 01:27:53.707
so I would think it would be that way
01:27:53.707 --> 01:27:54.842
with circlip's, but that is where I
01:27:54.842 --> 01:27:59.907
would start from as I look for that
01:27:59.907 --> 01:28:01.911
question and I am thinking about it, but
01:28:01.911 --> 01:28:15.735
it looks like it. Somebody, Lan (SP?)
01:28:15.735 --> 01:28:20.562
you sent me a link that I cannot open,
01:28:20.562 --> 01:28:21.551
if you sent me an email I would be happy
01:28:21.551 --> 01:28:23.582
to answer your question about a
01:28:23.582 --> 01:28:26.057
non-threaded article or a nut, if you
01:28:26.057 --> 01:28:28.891
can email that to me and I'll put that on
01:28:28.891 --> 01:28:37.223
my - I will put that on my contact
01:28:37.223 --> 01:28:41.519
information, oh my goodness - there. If
01:28:41.519 --> 01:28:43.706
you can send me that in an email, then I
01:28:43.706 --> 01:28:49.376
will be able to answer that question.
01:28:49.376 --> 01:28:50.374
Another question, our aircraft nuts and
01:28:50.374 --> 01:28:53.539
bolts classified in 7813? So, if they
01:28:53.539 --> 01:28:56.693
are entered separately and if they can
01:28:56.693 --> 01:28:59.102
meet the definition of a nut or a bowl as
01:28:59.102 --> 01:29:03.107
we just described in 7813, then yes,
01:29:03.107 --> 01:29:04.129
they would be classified under 7813 and
01:29:04.129 --> 01:29:05.341
not a part of the aircraft, because they
01:29:05.341 --> 01:29:10.729
would be parts of general use and there
01:29:10.729 --> 01:29:13.495
are a number - so, parts of general use
01:29:13.495 --> 01:29:17.469
entered separately are not considered a
01:29:17.469 --> 01:29:22.506
part of an item.
01:29:22.506 --> 01:29:27.078
I think I have got all the questions. I
01:29:27.078 --> 01:29:31.570
will give it another minute unless there
01:29:31.570 --> 01:29:39.983
is anything else. Okay, I am not seeing
01:29:39.983 --> 01:29:41.982
anything, but if I did not answer your
01:29:41.982 --> 01:29:43.987
question or you had more questions,
01:29:43.987 --> 01:29:45.985
please feel free to email me at my email
01:29:45.985 --> 01:29:46.987
address that is on the screen there and
01:29:46.987 --> 01:29:50.770
I would be happy to look into your
01:29:50.770 --> 01:29:52.767
question. Thank you, so much, I really
01:29:52.767 --> 01:30:02.366
appreciate your time!
01:30:02.366 --> 01:30:03.391
>>SPEAKER: Thank you, Jennifer, we
01:30:03.391 --> 01:30:05.362
hope that you found today's webinar very
01:30:05.362 --> 01:30:07.399
informative comedy continuing education
01:30:07.399 --> 01:30:09.393
credit code was placed in the WebEx chat
01:30:09.393 --> 01:30:12.309
and it will be emailed to all of the
01:30:12.309 --> 01:30:13.294
participants who logged into today's
01:30:13.294 --> 01:30:16.879
webinar via their email address within
01:30:16.879 --> 01:30:18.884
48 hours. As Jennifer mentioned,
01:30:18.884 --> 01:30:27.855
today's webinar will be posted on
01:30:27.855 --> 01:30:29.846
CBP.gov under the trade outreach
01:30:29.846 --> 01:30:30.853
webinars in the coming weeks. Thank you,
01:30:30.853 --> 01:30:32.849
everyone for joining us today and this

01:30:34.849 --> 01:30:34.849
afternoon, everyone! R